INTEGRAL POLICY

SURUS INVERSA S.L. is a private company specialized in recapturing value through reverse logistics and the sale of obsolete material, stock surplus, end-of-life products and scrap to secondary markets with the aim of maximizing returns for their clients. We are determined to extract value from unused waste from any origin, including waste generated from the dismantling of a ship, and to make sure that waste is properly managed. We know how wrongful waste management can impact the environment.

A key part of our business strategy is the commitment with the protection of the environment, taking every necessary action to minimize impacts, prevent pollution, and enforce safety and health measures for our workers. Furthermore, we have developed an Anti-bribery and Compliance Model, determining an ethical and behavioral code, mandatory for all employees of our company and other companies working for or in name of SURUS INVERSA S.L. The goal is to prevent any act against the law, including briberies and other similar acts. It is carried out with security guarantees of the information and the data that SURUS INVERSA S.L works with.

In this context, the company is committed to:

• Understand the needs of our clients and to satisfy them.
• Comply and ensure compliance with all laws and regulations applicable for the different activities developed by the company, as well as any other requirement from our clients or from the inside of the company.
• Anticipate to any health damage by establishing a safety in the workplace system based on prevention and/or removal of risks in all work positions.
• Determine a commitment to provide safe and healthy working conditions for the prevention of injuries and deterioration of health related to the job of our workers.
• Identify hazards and reduce risks for Safety and Health at Work, eliminating the danger whenever possible, substituting processes, operations, materials or equipment for less dangerous ones whenever possible, providing the appropriate personal protective equipment to our workers.
• Workers will be duly informed and instructed on the rules and preventive measures in force for their work, and will participate in all matters that affect safety and health at work.
• Protect the company’s information resources and the processing technology from external or internal, meant or unmeant threats in order to ensure the compliance of clauses of nondisclosure, authenticity, traceability, availability, legality and reliability of information.
• Commitment that both the Management and its staff must apply the established information security measures and establish the control and monitoring mechanisms thereof. For this, the company has implemented a set of objectives, measures, controls, procedures and actions aimed at protecting all assets, including both the information, the processes, the systems and the networks that support it. Our entire information security management system is based on continuous improvement.
• Keep continuous improvement in all processes, developing corrective and proactive measures to prevent error recurrence.
• Promote training and awareness actions for employees in order to improve their performance within the company and ensure the achievement of goals and milestones.
• Identify activities where crimes can be committed in the Guidelines for the Prevention of Criminal Offenses.
• Determine general policies, procedures, and mandatory regulations regarding information safety, correct management and anti-bribery, which will be spread to all employees at the company and all stakeholders.
• Forbid any behavior in conflict with the General Anti-bribery and Compliance Regulations. Disciplinary, corrective or penalty measures according to current work laws will be applied if necessary.
• Develop a channel to lodge a complaint for all employees within the organization and any external person that must share any piece of information, doubt or suspicion about a behavior that goes against our ethical code or the law. The email address buzoncompliance@surusin.com has been enabled for this or by post to Camino de las Huertas 18, 2º Pl. (28223 Pozuelo de Alarcón). In any event, retaliation of any kind against a reporter in good faith is prohibited.
• Employees at Surus are never allowed to promise, offer or give a bribe;
• Employees at Surus are never allowed to ask for or accept a bribe;
• Establish a Compliance committee, independent from any business decision, whose goal will be to monitor and control the Anti-bribery and Compliance Model, as well as to report about and manage any issue related to the Model.
• Determine ways for the notification, management and registry of incidences related to any of the management systems implemented in the organization.
• Manage all systems according to the principles of risk management, focusing on preventive measures over corrective actions.
• Consider management planning as an integral part in all processes within the organization, determining regular programs, goals and objectives to guarantee the compliance of the Policy and the continuous improvement of the integral management system.

Management extends this commitment to all employees and any person that acts on behalf of SURUS INVERSA S.L, who shall comply with this policy guidelines, which will be revised regularly in order to ensure they are appropriate for the activities of the organization.

Madrid, 03 March 2021

Surus Inversa S.L